Transfer pricing / Working reference
BEPS Action 13 — Documentation & CbCR
The BEPS Action 13 report establishing the master file, local file and country-by-country reporting approach.
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The T&M reading note
Why it deserves your time
Clarifies the original architecture and different purposes of the three documentation layers.
A suggested 15-minute first pass
Where to begin
- Compare the three reporting layers.
- Review the country-by-country reporting template.
- Consult current jurisdiction-specific requirements separately.
Read this edition in context
Foundational 2015 report. Filing obligations, thresholds and implementation should be checked in current domestic sources.
These notes describe the publication; they do not determine the treatment of a particular taxpayer or transaction.
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Official sourcewww.oecd.org Catalogue review: 2026-10-13